16 Cardozo Law Review 241 (1994); reprinted by permission of the Cardozo Law Review

Notes: Part I

31. The frequent
association of metaphor with image has led some
commentators to suggest that all metaphors are necessarily
visual. Most modern scholars nonetheless believe that metaphors can
theoretically appeal to any (or any combination) of the senses,
thereby allowing for the possibility of the "aural metaphors"
discussed in this Article. See, e.g, I.A. Richards, Principles of
Literary Criticism 119 (1925); Paul Ricoeur, The Rule of
Metaphor 207-15 (Robert Czerny trans., Univ. of Toronto Press
1977) (1975).

43. To this point, the
only work of legal scholarship to have
given even passing consideration to the implications of choosing one
scheme of modal metaphors over another is O'Fallon & Ryan,
supra note 22, at 896-97. The authors of that piece notably recommend
that the prevailing metaphorical model of "seeing" be replaced by one
of "listening."